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APPENDIX A

Descriptions of

Key Program Functions and

Program Support functions

A. KEY PROGRAM FUNCTIONS 

Key Program functions are listed below, based on which entities carry them out, in the following 

order: 1) NIOSH-only; 2) NIOSH/Program Contractor; 3) Contractor-only. 

NIOSH-Only KPFs

1. Document Approval Authority (NIOSH) 

The Document Approval Authority exercises approval authority by signature to permit 

use by the Program of a Dose Reconstruction Report, Site Profile Document, SEC 

Petition Evaluation Report, Site-Specific Technical Information Bulletin (TIB), and/or any 

other key Program function document created for use by the Program. Any exercise of 

such approval authority is treated as a key Program function under this policy, and the 

individual who exercises that authority shall ensure to the best of his/her ability, by a 

review of the document and the sources and preparers described within, that the 

exclusions and attributions required by these Implementing Procedures have been met 

before signing the document and approving it for use in the Program. 

2. NIOSH AOB/COB Officer (NIOSH)

The NIOSH AOB/COB Officer, who reports directly to the NIOSH Director, is responsible 

for ensuring to the best of his/her ability that any key Program function document 

disseminated by NIOSH conforms substantively and procedurally to all the provisions 

contained in this COB Policy Statement. In that regard, the AOB/COB Officer manages 

the process to ensure that all key Program function documents conform to the NIOSH 

AOB Policy and its Implementing Procedures. For example, the AOB/COB Officer will 

review all disclosures brought to his/her attention due to potential conflicts or concerns; 

investigate and resolve complaints about failure to disclose; may examine key Program 

documents for proper attribution; and examine the roles of the document owner, site, 

and subject experts, among others, in key Program documents. With regard to 

documents disseminated by Program contractors, the NIOSH AOB/COB Officer shall 

exercise similar oversight in consultation with the respective NIOSH Contact Officer 

Technical Representatives. In all instances, the NIOSH AOB/COB Officer may carry out 

his/her responsibilities in consultation with the NIOSH Director and/or other NIOSH and 

HHS employees as needed. 

NIOSH/Program Contractor KPFs

1. Site Profile Document Owner (NIOSH/ORAU)

A Site Profile Document1 Owner is responsible for coordinating and drafting all Site 

Profile Documents, ensuring that all relevant information is captured in the document, 

 1 "Site profile document" also includes any "Technical Basis Documents," or TBDs, related to the site. 
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evaluating information, and establishing or setting forth specific findings or conclusions. 

The Site Profile Document Owner is the primary writer/editor of the Site Profile 

Document. The Site Profile Document Owner has an affirmative duty to seek out all 

relevant data and to objectively evaluate all relevant input with no special consideration 

given due to the source (e.g., Site Expert or Subject Expert/Technical Specialist). 

All narrative or quantitative input to Site Profile Documents shall be clearly attributed2

to each source(s), including both Site and Subject Experts/Technical Specialists, 

wherever it appears or is relied upon within a Site Profile document. In addition, both 

Site and Subject Experts/Technical Specialists shall be clearly identified on the approval 

page of every Site Profile Document to which they contributed. A Site Profile Document 

Owner is responsible for any and all revisions to a Site Profile Document.

2. Site Expert (NIOSH/All Program Contractors)

A Site Expert is responsible for advising on site-specific issues and incidents as necessary 

to ensure the completeness and accuracy of Dose Reconstructions, Site Profile 

Documents and Special Exposure Cohort Petition Evaluation Reports, or to conduct 

Advisory Board-related reviews of such products, documents and reports. Site Experts 

are those individuals who, because of current or prior work experience (including 

consulting) at or for the site, possess or are aware of information that is relevant for 

reconstructing radiation doses experienced by claimants who worked at the site. 

Because of their work experience at or for sites under Program review and the need to 

prevent or remedy conflicts, Site Experts, if first provided a waiver, authorization, or 

approval to participate, shall play only a very limited role in accomplishing key Program 

functions. They may be used by a document owner in crafting a key Program document, 

to assist with data collection, and provide both data and opinions on data to that 

document owner. In all cases where such actions, information or prior studies or 

writings are included or relied upon by a key Program document owner, those actions 

and/or materials shall be both fully attributed to the Site Expert and reprinted, if at all, 

only in an Appendix of the key Program document. The Site Expert’s input shall also be 

maintained as appropriate elsewhere in the document record (for instance, in notes of 

formal interviews conducted with the Site Expert to obtain information).

Site Experts are not permitted to serve as document owners or authors, or to make 

formal public presentations on a key Program document. However, at a formal public 

presentation, a Site Expert may be called upon to answer questions and serve as a 

source of information to the presenter in response to questions that arise during a 

presentation.

3. Site-Specific Technical Information Bulletin Owner (NIOSH/ORAU)

A Site-Specific Technical Information Bulletin Owner is responsible for coordinating and 

drafting a TIB which addresses a technical issue or concern regarding dose 

reconstructions for a specific exposure that may occur at one or more specific DOE or 

 2 "Attributed” means the inclusion of footnotes, endnotes, a list of references, or other markings to identify the person, 

organization, or document sources for information in Program documents. The level of specificity of the attribution 

shall be appropriate to the importance of the information and may include, for example, document sections, 

paragraphs, tables or figures, or other key components of the document. 
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AWE facilities3, ensuring that all relevant information is captured in the document, 

evaluating information, and establishing or setting forth a specific approach to resolve 

the technical issue or concern. The Site-Specific TIB Owner is the primary writer/editor 

of the subject TIB. The Site-Specific TIB Owner has an affirmative duty to seek out all 

relevant information, and to objectively evaluate all relevant input with no special 

consideration given due to the source (e.g., Site Expert or Subject Expert/Technical 

Specialist). 

All narrative or quantitative input to a Site-Specific TIB shall be clearly attributed to each 

source(s), including both Site and Subject Experts/Technical Specialists, wherever it 

appears or is relied upon within a TIB. The specific DOE or AWE site to which the TIB 

applies shall be listed in the TIB. In addition, both Site and Subject Experts/Technical 

Specialists shall be clearly identified on the approval page of every Site-Specific TIB to 

which they contributed. A Site-Specific Technical Information Bulletin Owner is 

responsible for any and all revisions to a Site-Specific TIB.

4. Special Exposure Cohort Petition Evaluation Report Owner (NIOSH/ORAU)

A Special Exposure Cohort (SEC) Petition Evaluation Report Owner is responsible for 

leading and documenting the evaluation of a qualified SEC petition to determine the 

feasibility of performing dose reconstruction. This individual is the primary 

writer/editor of the SEC Petition Evaluation Report. The SEC Petition Evaluation Report 

Owner has an affirmative duty to seek out all relevant data and to objectively evaluate 

all relevant input with no special consideration given due to the source (e.g., Site Expert 

or Subject Expert/Technical Specialist). 

All narrative or quantitative input to SEC Petition Evaluation Reports shall be clearly 

attributed to each source(s), including both Site and Subject Experts/Technical 

Specialists, wherever it appears or is relied upon within the SEC Petition Evaluation 

Report. In addition, both Site and Subject Experts/Technical Specialists shall be clearly 

identified on the approval page of every SEC Petition Evaluation Report to which they 

contributed. An SEC Petition Evaluation Report Owner is responsible for any and all 

revisions to an SEC Petition Evaluation Report.

5. Scientific/Technical Peer Reviewer (NIOSH/All Program Contractors)

A Scientific/Technical Peer Reviewer is responsible for conducting a scientific and 

technical review of key Program documents (e.g., Dose Reconstruction Report, Site 

Profile Document, SEC Petition Evaluation Report, Site-Specific TIB, or materials 

responding to such documents as prepared by the technical contractor supporting the 

Advisory Board), and any other Program document created for use by the Program, to 

ensure the completeness and accuracy of such documents in that regard. Although 

classified as a KPF, a Scientific/Technical Peer Reviewer may be permitted to review a 

document pertaining to a site at which s/he is conflicted, subject to first obtaining the 

necessary remedial documentation to do so. As with Site Experts, this is done to balance 

the use of scientific and technical expertise important to the Program against the need 

to minimize the occurrence of conflicts of interest.

 3 “Site-Specific” TIB is one that applies to a single site, or a limited number of sites where those sites are identified by 

name in the document.
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6. Author/Owner of Site-Specific “White Paper” or Other Product Prepared for Purposes of 

Board, Working Group and/or Subcommittee Discussion (NIOSH/All Program 

Contractors)

An Author/Owner is considered responsible for drafting and/or leading the preparation 

of a site-specific “white paper” or other product that is created upon request of the 

Advisory Board or one of its Working Groups or Subcommittees, via the DFO, for 

purposes of assisting in Board members’ discussions and deliberations with regard to a 

specific site or sites.

Contractor-Only KPFs

1. Case Manager (SC&A)

A Case Manager is directly responsible for one or more cases under review by SC&A, 

and for directing those Technical Specialists who assist them in the case reviews. These 

responsibilities include planning, scheduling and cost control, as well as the technical 

quality of the end-product. Specifically, Case Managers supervise all work performed by 

the staff assigned to their cases; ensure that the work is performed in accordance with 

SC&A program procedures and quality assurance requirements; and report the status of 

assigned work to the Project Manager.

2. Dose Reconstructor (ORAU/SC&A)

A Dose Reconstructor is responsible for conducting dose reconstructions for the 

Program which include, but are not limited to, analyzing monitoring methods, 

performing uncertainty analyses, estimating organ or effective dose from available 

monitoring data, and incorporating any comments from Dose Reconstruction Report 

Reviewers. A Dose Reconstructor is responsible for any and all revisions to a Dose 

Reconstruction Report. 

3. Dose Reconstruction Reviewer (ORAU/SC&A)

A Dose Reconstruction Reviewer works under the supervision of a Lead Dose 

Reconstruction Reviewer, Case Manager or other managing individual to ensure that the 

dose reconstruction under review was performed in accordance with NIOSH regulations, 

procedures and guidelines, and (for advanced reviews) placing special emphasis on the 

NIOSH data collection process and on whether the review suggests flaws or biases in the 

dose reconstruction process.

4. Dose Reconstruction Report Peer Reviewer (ORAU/SC&A)

A Dose Reconstruction Report Peer Reviewer is responsible for conducting a review of 

the Dose Reconstruction Report to ensure that all appropriate sources of information 

for possible doses are included and that all calculations are accurate. 

5. Lead Dose Reconstruction Reviewer (ORAU/SC&A)

A Lead Dose Reconstruction Reviewer is directly responsible for all dose reconstruction 

reviews and blind dose reconstructions performed for the Program, and ensures that all 

individuals performing dose reconstruction reviews and blind dose reconstructions do 

so in accordance with applicable procedures, and that any deviation from those 

procedures receives proper review, approval and documentation.
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6. Worker/Site Profile Reviewer (ORAU/SC&A)

A Worker/Site Profile Reviewer conducts reviews of worker and site profiles and 

related data and analyses, pursuant to tasking by the appropriate COTR at the request 

of the Advisory Board or NIOSH, under the direction of the Lead Worker/Site Profile 

Reviewer. The Worker/Site Profile Reviewer determines whether NIOSH followed its 

applicable regulations, procedures and guidelines in assembling the Profiles, data

and/or analyses and has met NIOSH and Board requirements (both explicit and as 

determined in specific cases) for ensuring validity and scientific quality.

7. Lead Worker/Site Profile Reviewer (ORAU/SC&A)

A Lead Worker/Site Profile Reviewer is responsible for conducting and overseeing 

independent reviews of worker and site profiles and databases, as tasked by the 

Advisory Board or NIOSH. S/he also supports Case Managers and/or Project Managers in 

performing both basic and advanced reviews and blind dose reconstructions, and may 

support SEC Petition reviews.

8. SEC Petition Reviewer (ORAU/SC&A)

An SEC Petition Reviewer reviews SEC petitions and petition evaluations, pursuant to

tasking by the appropriate COTR at the request of the Advisory Board or NIOSH, under 

the supervision of the Lead SEC Petition Reviewer or other manager. The Reviewer 

evaluates whether an SEC petition was handled in accordance with applicable NIOSH 

procedures, as well as other technical issues as deemed necessary by the Advisory 

Board or NIOSH.

9. Lead SEC Petition Reviewer (ORAU/SC&A)

A Lead SEC Petition Reviewer is responsible for overseeing SEC petition reviews by 

ORAU or SC&A to ensure that the reviews are performed in accordance with Programspecific procedures, and that any deviation from those procedures receives proper 

review, approval and documentation.

B. PROGRAM SUPPORT FUNCTIONS 

1. Implementation Guide/General Guidance Owner (NIOSH/ORAU)

An Implementation Guide/General Guidance (IG/GG) Owner is responsible for 

providing basic guidelines on the general methods employed in reconstructing either 

internal or external doses, or other general (i.e., not site-specific) guidance on carrying 

out NIOSH responsibilities under the Program. The IG/GG Owner is the primary 

writer/editor of the Implementation Guide or other guidance document and is 

responsible for coordinating and drafting that respective document. The IG/GG Owner 

has an affirmative duty to seek out all relevant information, and to objectively evaluate 

all relevant input with no special consideration given due to the source (e.g., Site Expert 

or Subject Expert/Technical Specialist). 

All narrative or quantitative input to IG/GG shall be clearly attributed to each source(s), 

including both Site and Subject Experts/Technical Specialists, wherever it appears or is 

relied upon within the pertinent document. In addition, both Site and Subject 

Experts/Technical Specialists shall be clearly identified on the approval page of every 

IG/GG to which they contributed. 
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2. Multiple-Site Technical Information Bulletin Owner (NIOSH/ORAU)

A Multiple-Site Technical Information Bulletin Owner is responsible for coordinating 

and drafting a TIB which addresses a technical issue or concern regarding dose 

reconstructions for a specific exposure that may occur at multiple DOE or at AWE 

facilities4, ensuring that all relevant information is captured in the document, evaluating 

information, and establishing or setting forth a specific approach to resolve the 

technical issue or concern. The Multiple-Site TIB Owner is the primary writer/editor of 

the TIB. The Multiple-Site TIB Owner has an affirmative duty to seek out all relevant 

information, and to objectively evaluate all relevant input with no special consideration 

given due to the source (e.g., site expert or subject expert). All narrative or quantitative 

input to a Multiple-Site TIB shall be clearly attributed to each source(s), including both 

Site and Subject Experts/Technical Specialists, wherever it appears or is relied upon 

within such a TIB. Each DOE or AWE site to which the TIB applies shall be listed in the 

TIB. In addition, both Site and Subject Experts/Technical Specialists shall be clearly 

identified on the approval page of every TIB to which they contributed. A Multiple-Site 

Technical Information Bulletin Document Owner is responsible for any and all revisions 

to a Multiple-Site TIB. 

 

3. Subject Expert/Technical Specialist (NIOSH/All Program Contractors)

A Subject Expert/Technical Specialist is responsible for advising on scientific and 

technical issues and incidents as necessary to ensure the completeness and accuracy of 

Site Profile Documents and SEC Petition Evaluation Reports and/or reviews and 

evaluations of documents, analyses and data conducted by NIOSH and/or its Program 

contractors, as appropriate. In contrast with Site Experts, Subject Experts and Technical 

Specialists are those individuals who have expertise in the subject matter of certain 

activities performed at a site, but do not necessarily have any current or prior work 

experience at or for the subject site itself.

 4 A “multiple-site” TIB is one that applies in a generic fashion to a number of sites that are not designated as such in 

the document.